TRAINING AND ASSURING PERSONNEL COMPETENCE

Transcription

1 Title of document ONR GUIDE TRAINING AND ASSURING PERSONNEL COMPETENCE Document Type: Unique Document ID and Revision No: Nuclear Safety Technical Assessment Guide Date Issued: July 2017 Review Date: July 2020 Approved by: E Vinton Professional Lead Record Reference: (2017/278941) Revision commentary: Fit for Purpose Review TABLE OF CONTENTS 1. INTRODUCTION PURPOSE & SCOPE RELATIONSHIP TO SITE LICENCE AND OTHER RELEVANT LEGISLATION RELATIONSHIP TO SAPS, WENRA REFERENCE LEVELS AND IAEA SAFETY STANDARDS ADVICE TO INSPECTORS REFERENCES ANNEX 1: SAPS RELEVANT TO TRAINING AND COMPETENCE ANNEX 2: GUIDANCE ON INSPECTING THE IMPLEMENTATION OF LICENSEE ARRANGEMENTS Office for Nuclear Regulation, 2017 If you wish to reuse this information visit for details. Published 07/17 Page 1 of 27

2 1. INTRODUCTION 1.1 ONR has established its Safety Assessment Principles (SAPs) which apply to the assessment by ONR specialist inspectors of safety cases for nuclear facilities that may be operated by potential licensees, existing licensees, or other duty-holders. The principles presented in the SAPs are supported by a suite of guides to further assist ONR s inspectors in their technical assessment work in support of making regulatory judgements and decisions. This technical assessment guide is one of these guides. 2. PURPOSE & SCOPE 2.1 The Office for Nuclear Regulation (ONR) of the Health and Safety ONR (HSE) has the responsibility for regulating the safety of nuclear installations in Great Britain. The Safety Assessment Principles (SAPs) for Nuclear Facilities [Ref 1] provide a framework to guide regulatory decision-making in the nuclear permissioning process. They are supported by Technical Assessment Guides (TAGs) which further aid the decision-making process. 2.2 This TAG is principally intended to provide guidance to aid inspectors in the application of SAP EHF.8, which states that a systematic approach should be taken to the identification and delivery of personnel competence, and its supporting Para 457. It also assists in the application of other SAPs which set out expectations of licensees training processes and arrangements for assuring competence. 2.3 The TAG also provides guidance to inform inspection activities carried out to judge compliance with Licence Condition 10 (training) and Licence Condition 12 (duly authorised and other suitably qualified and experienced persons). Annex 2 incorporates guidance on inspecting the implementation of arrangements that was previously included within T/INS/10 (LC10) and T/INS/012 (LC12) which are now withdrawn. The guidance in the Annex is complementary to the main body of this TAG and both should be read and applied together as appropriate. 3. RELATIONSHIP TO SITE LICENCE AND OTHER RELEVANT LEGISLATION 3.1 The Nuclear Site Licence Conditions place legal requirements on the licensee to make and implement arrangements to ensure that safety is being managed adequately. 3.2 All licence conditions are to some extent relevant to the licensee s arrangements for ensuring that staff are appropriately trained and that they are suitably qualified and experienced. However the following licence conditions, and selected sub-conditions, are particularly pertinent: Licence Condition 10: Training 1) The licensee shall make and implement adequate arrangements for suitable training of all those on site who have responsibility for any operations which may affect safety. 2) The licensee shall submit to the ONRONR for approval such part or parts of the aforesaid arrangements as the ONRONR may specify. 3) The licensee shall ensure that once approved no alteration or amendment is made to the approved arrangements unless the ONRONR has approved such alteration or amendment. 2017/ Page 2 of 27

3 Licence Condition 12: Duly authorised and other suitably qualified and experienced persons 1) The licensee shall make and implement adequate arrangements to ensure that only suitably qualified and experienced persons perform any duties which may affect the safety of operations on the site or any duties assigned by or under these conditions or any arrangements required under these conditions. 2) The aforesaid arrangements shall also provide for the appointment, in appropriate cases, of duly authorised persons to control and supervise operations which may affect plant safety. 3) The licensee shall submit to the ONR for approval such part or parts of the aforesaid arrangements as the ONR may specify. 4) The licensee shall ensure that once approved no alteration or amendment is made to the approved arrangements unless the ONR has approved such alteration or amendment. 5) The licensee shall ensure that no person continues to act as a duly authorised person if, in the opinion of the ONR, he is unfit to act in that capacity and the ONR has notified the licensee to that effect. Licence Condition 6: Documents, Records, Authorities and Certificates 1) The licensee shall make adequate records to demonstrate compliance with any of the conditions applied to this licence. Licence Condition 9: Instructions to persons on the site 1) The licensee shall ensure that every person authorised to be on the site receives adequate instructions (to the extent that is necessary having regard to the circumstances of that person being on the site) as regards the risks and hazards associated with the plant and its operation, the precautions to be observed in connection therewith and the action to be taken in the event of an accident or emergency on the site. Licence Condition 11: Emergency arrangements 1) Without prejudice to any other requirements of the conditions attached to this licence, the licensee shall make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects. 5) The licensee shall ensure that such arrangements are rehearsed at such intervals and to such extent as the ONR may specify or, where ONR has not so specified, as the licensee considers necessary. 6) The licensee shall ensure that such arrangements include procedures to ensure that all persons in his employ who have duties in connection with such arrangements are properly instructed in the performance of the same, in the use of the equipment required and the precautions to be observed in connection therewith. Licence Condition 17: Management Systems 2017/ Page 3 of 27

4 1) Without prejudice to any other requirements of the conditions attached to this licence, the licensee shall establish and implement management systems which give due priority to safety. Licence Condition 26: Control and supervision of operations The licensee shall ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by the licensee. Legal requirements for training are also set out elsewhere, for example the Health and Safety at Work Act (HSWA) and the Ionising Radiations Regulations (IRRs). The Management of Health and Safety at Work Regulations require the employer to ensure that employees and temporary workers are provided with adequate health and safety training and that they are not required to carry out work which exceeds their ability to carry out work without risk to themselves or others. The IRRs place duties on the employer to ensure that employees and others working with, or affected by, the employer s work with ionising radiation are given appropriate training. The principal requirements are set out in Regulation 14 of the IRRs. 4. RELATIONSHIP TO SAPS, WENRA REFERENCE LEVELS AND IAEA SAFETY STANDARDS Relevant SAPs 4.1 ONR s expectations concerning licensee s arrangements for training and assuring personnel competence are set out in a number of SAPs. The primary reference is SAP EHF.8 which states: A systematic approach to the identification and delivery of personnel competence should be applied. Para 457 expands upon SAP EHF.8: The process for identifying and delivering competence should encompass the phases of: job analysis; identification of competence requirements; training needs analysis; training programme design and implementation; formal assessment of competence; and training programme evaluation. The process should be applied to all whose actions could impact on safety, whether they are an employee or a contractor, including personnel who may not interact directly with plant or equipment (see paragraph 447). Close supervision and monitoring should be maintained until individuals are demonstrably competent to perform their tasks. 4.2 SAP EHF.8 is linked with SAP EHF.3 which states: A systematic approach should be taken to identify human actions that can impact safety for all permitted operating modes and all fault and accident conditions identified in the safety case, including severe accidents. Para 447 expands upon SAP EHF.3 and states that: This principle includes identifying all the safety actions of personnel responsible for monitoring and controlling the facility and of personnel carrying out maintenance, testing and calibration activities. It also includes consideration of the impact on safety arising from engineers, analysts, managers, directors and other personnel who may not interact directly with plant or equipment. 2017/ Page 4 of 27

5 4.3 Other SAPs and their supporting text also make reference to the need for a process to carry out training and assure that appropriate competencies are delivered and maintained. These are summarised in Annex 1. IAEA Safety Standards 4.4 The expectations for the provision of training and competence are identified in IAEA GS-R-3 [Ref 2] under: Requirement 21 and Requirement 24 which places a responsibility on the licensee for the protection of it staff against occupational exposure by providing suitable and adequate human resources and appropriate training in protection and safety are provided, as well as periodic retraining as required to ensure the necessary level of competence Requirement 26 which states that licensees shall provide workers with adequate information, instruction and training for protection and safety. Specifically, that licensees shall: o o o provide all workers with adequate information on health risks due to their occupational exposure in normal operation, anticipated operational occurrences and accident conditions, adequate instruction and training and periodic retraining in protection and safety, and adequate information on the significance of their actions for protection and safety. provide those workers who could be involved in or affected by the response to an emergency with appropriate information, and adequate instruction and training and periodic retraining, for protection and safety. maintain records of the training provided to individual workers. 4.5 The guidance in this TAG is consistent with the systematic approach to training advocated by the IAEA in [Ref 4], which is referred to in IAEA NS-G-2.8 [Ref 5]. WENRA safety reference levels 4.6 The guidance is consistent with WENRA Reactor Safety Reference Levels Issue D: Training and Authorization of NPP staff (jobs with safety importance) [Ref 6], against which it has been benchmarked. 5. ADVICE TO INSPECTORS 5.1 It is essential that all personnel whose activities have the potential to impact on nuclear safety are suitably qualified and experienced (SQEP) to carry out their jobs. This includes both those who directly carry out operations and others such as directors, managers, designers, safety case authors etc. whose roles, if inadequately conceived or executed, may affect safety in less visible ways for example, through introducing latent technical or organisational weaknesses. The licensee should therefore put in place robust arrangements for identifying its competence needs and assuring these are met and maintained. These arrangements are needed to comply with the requirements of LC12. The arrangements should clearly define the licensee s interpretation of SQEP, and should identify those who are required to be SQEP. Staff who discharge nuclear safety roles should be included within the licensee s organisational baseline -see NS-TAST-GD-065 [Ref 13]. 2017/ Page 5 of 27

6 5.2 Training is a fundamental mechanism through which personnel acquire, and maintain, the skills and knowledge needed to perform a job to defined standards. In other words, training should be instrumental in developing and sustaining competence. IAEA has defined competence as the ability to put skills and knowledge into practice in order to perform a job in an effective and efficient manner to an established standard [Ref 4]. ONR concurs with this definition, which is widely accepted within the international nuclear community. Other factors contributing to a person s competence include the person s prior experience, aptitudes, attitudes, behaviours, skills and qualifications. Competence can therefore broadly be equated to SQEP. The licensee should have arrangements in place to define and deliver the training needed to sustain competence, and to comply with the requirements of LC LC12 further provides for the appointment of Duly Authorised Persons (DAPs). DAPs are usually identified as individuals who are in direct control or supervision of operations or activities that impact on the safety envelope of the facility. Their appointments are therefore subject to additional management controls covering areas such as appointment and assessment. Roles for which DAPs must be appointed should be specified in the licensee s LC12 arrangements, and a register kept of such persons (see Annex 2 for further detail). However, the general principle that persons whose activities may impact upon nuclear safety should be appropriately trained, and their competence adequately assured, is similar for SQEPs and DAPs. 5.4 ONR does not assess the competence of licensee staff directly, or authorise, e.g., reactor desk engineers as is the case in some regulatory regimes. ONR s approach is to seek confidence that the licensee has put in place, and is implementing, effective and proportionate arrangements for training and competence assurance for all personnel whose activities may impact upon plant safety. This should cover both licensee employees and others such as contractors whose actions could impact upon nuclear safety. A well-designed training and competence management system should adequately address the following elements: analysis of roles and associated competencies identification of learning objectives and training needs training programme design selection of appropriate training methods and media assessment of competence evaluation of training effectiveness organisation and support of the training function 5.5 The above elements are consistent with those identified in the Systematic Approach to Training, advocated by the IAEA in Technical Report 380 [Ref 4], and implicit in other publications (e.g. ACSNI [Ref 9]). ONR expects that at each stage these be applied in a proportionate and targeted manner. This assessment guide presents a summary of the reasons why each element is an important component of a licensee's training arrangements, and sets out the principal factors which should be considered by the ONR Inspector. 5.6 The emphasis that the Inspector gives to assessing different elements of a licensee s training and competence arrangements will depend upon the case being assessed. For example, where the tasks involved in carrying out a role are already well-defined, it may not be necessary to scrutinise closely the processes used to analyse the role and define competence and training needs. Conversely, where new activities are being developed, closer examination of the approach which the licensee takes to analysing these factors may be appropriate. As an overriding principle, the Inspector should consider the safety significance of the activities which the licensee 2017/ Page 6 of 27

7 carries out and adopt a proportionate and targeted approach to applying the guidance in this document. Analysis of Roles and Associated Competencies 5.7 In order to develop a suitable and effective training programme, it is necessary first to identify the roles that must be performed. ONR expects the licensee to show how it has identified all roles that have the potential to impact on nuclear safety. This includes roles discharged by staff who do not have immediate hands-on contact with the facility, such as those who work in plant design and analysis and outage planning, and should cover those working in corporate offices as well as on-site. It should also include managerial roles and should extend up to and including the Board. The licensee should have in place a process for ensuring that safety roles performed by staff whom it does not employ directly - such as contractors and agency staff have been suitably identified and that these are subject to the licensee s arrangements. The tasks associated with each role then need to be determined so that competence and training needs can be established. 5.8 Identifying the components of a role, and the competencies needed to carry them out, may involve the use of job or task analysis. Where it exists this should build on and extend any existing task analysis that has been developed in support of human factors integration (see NS-TAST-GD-058 [Ref 17]) A range of task analysis techniques are available to the licensee, and the choice of technique should depend on the nature of the activity and the information which the licensee's analyst is seeking to extract. For example, some techniques are oriented towards describing the cognitive demands made by the task, whereas others are better at describing procedural steps or interactions between people. Useful guidance on the selection and use of task analysis techniques is provided in [Ref 8]. 5.9 The analysis should draw upon sources such as the plant safety case, procedures, staffing levels, statements of personnel responsibilities, the licensee s overriding nuclear policy, regulatory requirements and operational experience feedback. For new facilities, where sources such as operational experience feedback are not available, the analysis may need to place more emphasis on expert judgement, simulation and desk-top exercises. Job and task analysis can be a resource-intensive activity, and it may not be necessary for detailed analysis to be performed for every role. It may also be possible to define families in which several related roles are grouped together so that generic competence needs are identified For each role and associated task, the competencies needed to carry out the work should be determined. The set of competencies should include both technical elements and others which may be less tangible, but which are no less important, such as decision making, challenge, management and leadership, communication and behavioural skills, etc. The competence requirements for all nuclear safety roles are expected to include an awareness of the importance of sustaining and contributing to a strong safety culture and the importance of attitudes and behaviours in relation to this. All staff should understand why nuclear safety matters and their roles and responsibilities for working in such a way that safety is the overriding priority. Some licensees may define families in which roles with similar competence needs are grouped together. The stated levels of competence needed to discharge each of these related roles then vary according to the nature of the work for example, more qualifications and experience may be required for roles which include authority to make significant nuclear safety decisions. This approach can help the licensee to manage its staff competence and personal development needs and support succession planning. 2017/ Page 7 of 27

8 5.11 When considering the range of competencies that are needed to fulfil a designated role, the licensee should consider the full range of operating modes and all fault and accident conditions identified in the safety case, including severe accidents The ONR Inspector should confirm that the licensee has a structured process in place to identify the tasks which are to be performed for each role, and the competencies needed to perform the associated tasks. The output of this process should contribute towards the specification of a role profile. An individual post may include a number of roles, and these should be set out in the job description. Where this is the case, consideration should also be given to the integration of these roles within a post to ensure they are compatible and do not either overload individuals or create conflicts in relation to their requirements. The job description and role profile should explicitly include, or reference, the competencies needed to carry out the associated activities In addition to consideration of individual roles and tasks, the analysis should include consideration of the way in which these come together and how, team and organisational performance can impact upon safety. This should input to and be reflected in the process for identification of required competencies When considering the range of competencies that are needed to fulfil a designated role, the licensee should consider circumstances where an individual may be called upon to deputise for another person for example, at times of sickness or holiday. Although the deputy may not possess the full range of competencies required to carry out the work on a long-term basis, the licensee should identify the principal safety-related activities and ensure that the Deputy is, and remains, competent to carry out these activities The Inspector should consider: i) has a suitable analysis been carried out to identify those roles that may impact on safety, including corporate as well as plant functions; ii) is the analysis sufficiently detailed to provide confidence that all safety-related roles and responsibilities have been identified; iii) does the analysis include consideration of the full range of operating modes and all fault and accident conditions identified in the safety case, including severe accidents. iv) is the analysis current - i.e., has it been maintained to take account of plant, equipment, procedural or organisational changes; v) have the competencies required to carry out the tasks or activities associated with each role in an efficient and effective manner to the designated standards been formally identified; vi) has the identified set of skills, knowledge and competencies been used to inform the selection criteria for specific roles and posts; vi) Do the identified competencies include managerial, leadership and behavioural as well as technical factors? and has consideration been given to the competencies required to support team and organisational performance as well as individual roles. Identification of learning objectives & training needs 5.16 The analyses of roles, tasks and competencies logically give rise to the generation of a set of learning objectives. These objectives should inform the development of a set of 2017/ Page 8 of 27

9 training needs, and should be used to derive the criteria, or standards, against which the trainee is assessed during and/or after training Although licensees may choose to put their staff through training programmes which cover all the learning objectives identified in this way, this may not be essential. Each person will bring certain skills and experience to their job and a review of these, and application of appropriate selection techniques, may obviate the need for training to be provided in every facet of the job. It is reasonable for the licensee to consider the competencies which a person already has, to carry out a gap analysis and then to target its training effort on those areas where the person is not demonstrably competent. Nonetheless, in circumstances where training is waived, the licensee should demonstrate that the waiver is warranted for example, by ensuring that the person is assessed against the learning objectives and shown to be competent, or that his/her level of performance during previous assessments corresponds to the standards set out for the role in question (see Assessment of Competence section later in this TAG) Although it is important that the licensee s approach to staff selection is rigorous and effective (see the IAEA guidance in [Ref 5]), ONR places emphasis on the adequacy of the licensee s training arrangements and, in particular, the measures used to determine, monitor and sustain competence. Regardless of the previous experience and qualifications of the candidate, the licensee should ensure that the competencies needed of each role and post-holder have been identified systematically, and that training is provided for all those areas in which the person is not able to demonstrate an adequate level of competence. As noted above, these should include both technical competencies and other areas such as decision making, management and leadership, communications, behavioural, attitudinal etc The Inspector should consider: i) has the output of the task analysis been distilled into an outline set of training needs; ii) does the set of training needs take account of the qualifications, skills and experience of the employee; iii) have the standards which should be achieved in order for a person to be considered competent been defined; iv) is the need for refresher training in defined elements of competence acknowledged and formalised? Training programme design 5.20 A training programme should be designed to help develop and maintain the competence of all personnel with safety responsibilities. The starting point for the training programme should be the competence requirements and learning objectives of the role-holder. The training programme should specify how those objectives are to be achieved. The programme therefore needs to take account of all the elements of training considered in this document. In this sense, the training programme can be viewed as gathering the different elements into a focused and coordinated schedule to support the development of competence for a given role. It should include detailed plans setting out the learning objectives and written procedures on how to conduct each training session. As above there may be a need to address team working, command and control, as well as individual task performance (e.g., for control room staff or for those with emergency response roles). It should be recognised that there is 2017/ Page 9 of 27

10 a need to inculcate a positive safety culture in all staff, and training programmes should seek to build in and promote an awareness of safety culture and its attributes Design of the training programme should give consideration to the most effective means of meeting competence requirements and should consider whether the use of training is appropriate and the role that it plays. This will have overlap with other aspects such as task and equipment design and the development of documentation such as procedures and instructions. Where task analysis is used to inform competence requirements and learning objectives, the same task analysis should be used elsewhere in the design process including the development of procedures and instructions (see NS-TAST-GD-060 [Ref 18]). This helps to provide a clear demonstration that tasks are controlled either through training or appropriate use of procedures Initial training programmes should cover all the training needed to enable personnel to work in specified roles and posts. This should include basic induction training which applies to all workers and which covers items such as facility hazards and risks and their control measures, working practices, actions in event of emergencies etc; and job-specific training. In addition to the outputs of the role and task analysis, the plant safety case should be used to identify activities which warrant particular attention during training. For example, tasks upon which significant safety claims are made should be highlighted in training and should be extensively trained to ensure their reliable performance. Tasks which are complex or which are performed infrequently, and hence subject to irregular practice, may also need to be drawn out and given special attention. In the case of infrequent tasks consideration should be given to the timing of training and delivery of this on a just in time basis It is important that all personnel, from the Board down, receive training which supports the safety culture of the organisation, by inculcating the right safety attitudes and informing personnel about the behaviours and management arrangements which help to ensure both personal and plant safety. The need for training to reinforce an appropriate safety culture, as well as enabling the acquisition of technical competence, was recognised by ACSNI [Ref 7,9], and is acknowledged by IAEA [Ref 5]. Such training should encompass lessons learned from case histories of major accidents and events world-wide, and the underlying organisational and cultural factors. Contractors should be included in such training Continuing training must also be programmed to help maintain competence, especially for tasks associated with roles which are safety-significant and those which are complex or infrequently performed (e.g. by those deputising for others). Different groups may have differing continuing training needs. For example, operations staff should have the opportunity to rehearse knowledge of the safety case and operating rules, and to engage in team training. Maintenance personnel may require training in the use of equipment needed during infrequently performed activities and in the relevance of their work to the safety case. Supervisors and managers should receive training in management of safety, leadership, communication, and other supervisory skills. Training should be used to update personnel on operational experience feedback and the implications of modifications to plant, operating regime and instructions as well as personal development needs. The periodicity of training required for some activities, such as fork-lift truck driving and fire-fighting, is set out in nationally defined standards. Work to reinforce a positive safety culture should be a consistent feature of continuing training Training of staff involved in dealing with emergencies and beyond design basis conditions is an important aspect of continuing training (Licence Condition 11, SAP AM1, para 643). Training should address a comprehensive range of scenarios, both to 2017/ Page 10 of 27

11 support the development of personnel competence and to improve the facility s emergency preparedness and response arrangements. This should include consideration of the full range of competencies and include considerations of aspects such as leadership, interpersonal communications, stress resilience and decision making The impact of organisational change on training should not be underestimated. Changes which materially affect individuals roles for example, where they move to different jobs or where they take on additional roles may require different competencies. Instances where the nature of the work carried out on the facility changes for example, from construction to commissioning, from commissioning to operations or from operations to decommissioning - may also call for changes in staff competencies. Licensees arrangements under LC36 should explicitly consider the competencies required during and following an organisational change and should demonstrate that staff affected by the change are SQEP for any changed roles (see NS-TAST- GD -048 Organisational Capability, [Ref 14]). The management of change arrangements should include reference to training and assessment programmes as part of this demonstration. Licensee Directors and Managers, who are charged with determining the need for, and agreeing, organisational changes, should be trained to understand and manage the organisational change process. They should be made aware of the need to control organisational drift arising from successive changes The Inspector should consider: i) has the licensee established an initial training programme for all personnel whose activities at work might impact upon safety, including the Board, managers, contractors as well as other staff; ii) does the initial training programme include induction training to ensure a basic understanding of the employee's responsibilities, safe working practices, generic safety-related matters and safety management systems; iii) does the training programme demonstrate how the role-specific training needs are to be met; iv) does the training programme reference task analyses, operating experience and the plant safety case including the PSA, to identify activities which are safetysignificant, complex or infrequent and which warrant particular attention during training; v) does the training programme recognise the need to address leadership, managerial, behavioural, communication and safety culture issues as well as individual competence; vi) has the licensee established a continuing training programme for all personnel whose activities at work might impact upon safety; vii) does the continuing training programme take account of the demands of each role: e.g., the safety significance of different tasks; the need to refresh infrequently practised skills or inform changes to plant, equipment or instructions; the need to meet nationally defined standards; viii) does the continuing training programme clearly define and justify the training periodicities for different activities; 2017/ Page 11 of 27

12 ix) does the licensee acknowledge the need to implement training when new systems, processes and plant are developed or to update personnel on operational experience feedback. x) does the licensee acknowledge the need to review competence requirements during and following periods of organisational change (and as part of its succession planning arrangements) and put in place training programmes to deliver and sustain appropriate competencies; xi) does the training programme identify when training is to be delivered, and how it should be delivered, assessed and evaluated; xii) is training consistent with, and does it continually seek to reinforce, a positive safety culture? Selection of appropriate training methods & media 5.28 The training media and methods which are used to develop the competencies required in different roles should be both effective and practicable. This demands that careful attention is given to the choice of training media and to the way in which those training media are then used (i.e., the training method). The licensee should therefore be able to show that it has considered and identified the most appropriate media and methods for use in training different tasks A range of different training media are available, including the following principal examples: i) Classroom teaching may be most suitable for introductory material and where detailed information of a theoretical or conceptual nature needs to be learned. This medium also allows tasks to be talked- or walked-through in a seminar or workshopstyle approach. However, classroom teaching allows the trainee limited opportunity to gain hands-on experience in performing a practical task, or to put conceptual learning into practice. ii) On-job training is an essential part of most training programmes and provides a realistic environment for the trainee. However, it can be difficult to ensure systematic and controlled training on the job because the learning environment may be less easily controlled. In addition, concerns about the potential impact of trainee error on safetysignificant tasks limit the suitability of this approach for some activities. The licensee should be able to demonstrate that on-job training is properly specified, provided by people suitably prepared to carry out that function, and that adequate control and supervision (LC26) is in place. iii) Simulators allow the rehearsal of practical skills under controlled conditions. Fullscope, high fidelity control room simulators are essential for nuclear power reactors and for other nuclear installations are regarded as a highly desirable, though expensive, requirement to train control room operators to deal with fault and emergency conditions as well as planned plant manoeuvres - the Sizewell B simulator was required by the Layfield Public Inquiry [Ref 10] to be available for training one year before reactor start-up. WENRA [Ref 6] states that control room operators should spend at least 5 days on the simulator per year. Part-task training can be used to focus training on specific elements of the operators' tasks, and part-task simulators, employing varying degrees of physical fidelity, can be used to train either practical or conceptual skills. Simulators and replica equipment may be used to train groups of staff other than control room operators; mock-ups of plant items, for example, are a valuable aid to maintenance staff and others who need to learn about the way in which 2017/ Page 12 of 27

13 these items work, and to prepare them out with a potentially hostile environment. This can also help in dose minimisation. Low fidelity task simulation (e.g., table-top exercises) may also be used. iv) Open learning techniques, in which training is provided through structured selfteaching packages, are increasing in popularity as technology developments continue, owing to their flexibility and cost-effectiveness. These techniques may employ advanced technology such as computer-based packages and interactive video as well as more conventional methods. Care must be taken to ensure that open learning is fit for purpose, and that it is not used at the expense of other forms of training without justification and demonstrable benefits. v) Tool-box talks, which may not be formally structured in the same way as other training approaches, can play an important role in training. These will typically involve discussions, often led by a manager or Team Leader, on factors affecting the way in which jobs are carried out for example, adherence to procedures, safety culture, communications etc Choosing an appropriate training medium does not of itself guarantee that training will be satisfactory. The way in which the training medium is used is of utmost importance. For example, the control room simulator can be used to practise responding to faults as well as undertaking key operations such as reactor start-up or shutdown; training can be given to shift teams or to individuals; classroom instruction can be based around a lecture-style approach or a workshop approach which encourages trainee participation; on-job training is better carried out under the direction of a SQEP individual, working to a set of defined training objectives which may be supported by detailed work instructions, as opposed to a less structured approach of merely watching the activity being performed; feedback on trainee performance can be provided concurrently or via a debrief, and so on When the training method has been determined, attention should be given to the materials needed to apply the training method and to planning its implementation. The design and use of items such as training manuals, lessons plans, simulator exercise scenarios, data recording sheets and other supporting equipment need careful consideration in order to ensure a structured and effective use of the training method The Inspector should ensure that the licensee has considered the choice of training methods, and the way in which these methods are used, as well as the training media. The licensee should be able to demonstrate that the selected training methods and media promote effective development of the learning objectives and competencies which have previously been specified The Inspector should consider: i) is the licensee s choice of training media and training method based upon a consideration of how best to achieve the learning objectives; ii) are the training methods developed, planned and applied by personnel who are familiar with current practice regarding training/instructional techniques; iii) is training delivered by personnel who have acquired relevant training qualifications or equivalent experience; iv) are the training methods subject to periodic review to ensure that they are appropriate, and reflect best current practice; 2017/ Page 13 of 27

14 v) are simulators and other training media kept up-to-date such that they reflect changes to actual plant and equipment; vi) are the methods for on-job training appropriate; vii) does the training method take account of the supporting material which is needed - e.g. lesson plans, simulator scenarios, etc.? Assessment of competence 5.34 Licence Condition 12 requires that each person who carries out activities which may affect the safety of operations on a nuclear site must be suitably qualified and experienced (SQEP). Licence Condition 12 defines three categories of people who need to be SQEP. Whilst there is some flexibility in how this may be undertaken, the requirement to be SQEP applies to all three categories For some posts it may also be necessary to designate persons who control and supervise operations which may affect safety as Duly Authorised Persons (DAPs) see Annex 2. Although training plays an important role in developing the necessary competencies to become a SQEP or DAP, it does not itself guarantee competence: if training is poorly specified or targeted, or the trainee is not suited to the job, then a person may fail to achieve an acceptable level of performance For these reasons, ONR regards the assessment of trainee competence and, subsequently, the periodic re-assessment of personnel, as a key element in the process of developing and maintaining the competencies needed to function as a SQEP or a DAP. Assessment serves the following important functions: i) properly defined and carried out, it provides a means of demonstrating that learning objectives have been achieved and a level of competence attained; ii) it can point to a need for refresher or additional training through identifying shortfalls in performance; iii) it can indicate whether training has been effective in developing the required competencies. In particular, assessment can point to deficiencies in the identification of training needs, the choice of training methods or the training programme The licensee should therefore satisfy itself that all staff and contractors whose actions have the potential to impact upon nuclear safety meet its competence expectations. When an individual is first appointed to a role he/she may not be fully competent to carry out all the duties of that role. The competence assessment process should therefore be used to inform a management decision to restrict the individual s range of tasks to those for which they are competent (e.g. a C&I engineer may be competent to work on most instrumentation but may not be confirmed as SQEP to work on guard lines and is therefore restricted from doing so). Licensee management should also encourage staff and contractors to raise any concerns about their own competence or readiness to carry out a task and to seek further training or advice as necessary. Assessment methods 5.38 Licensees may use a range of different assessment methods. Their suitability will depend upon the training method and the nature of the competency which is being assessed. The classical view of assessment as a paper-based question and answer session may be appropriate for some activities, but will be quite inappropriate for many 2017/ Page 14 of 27

15 others. For example, it might be a sound means of assessing a trainee's understanding of principles concerning the transfer of heat across different mediums, but would not necessarily give an accurate indication of a trainee's practical competence in operating a master-slave manipulator arm. Assessment may take place on-the-job, or in a controlled training/assessment environment such as a control room simulator, a workshop or a classroom. It may take place as a specific, defined activity or as a continual assessment in the context of training or actual job performance. An overview of issues relating to competence assessment is provided in Competence Assessment for the Hazardous Industries Ref In some circumstances, the licensee may wish formally to waive some parts of training. Such waivers should be kept to a minimum, but where training is waived, the licensee should ensure that the affected person is assessed to the same, or an equivalent, standard. This provides a basis for demonstrating that the person is competent, despite not receiving the waived part of training. Where credit is claimed for prior training and competence of contractors, the licensee should be able to show how it has satisfied itself that the contractor s training and competence assurance arrangements are adequate and that they meet the licensee s expectations (and see NS-TAST-GD Procurement of Nuclear Safety Related Items or Services [Ref 15]) Assessment may involve carrying out real or simulated tasks or surrogates which have been shown, or are judged by the licensee, to be representative of the real job demands. As such, assessment methods can include written, oral or practical demonstrations of learning or competence. It is preferable that assessment is carried out by persons independent of the training itself. Some of the merits and disadvantages of different approaches to assessment are discussed in [Ref 11] Nonetheless, for any assessment method, the licensee should be able to demonstrate that the assessment process is: a) valid; i.e., it provides a reasonable indication of a person's likely performance on the real job. The criteria used to judge performance should therefore remain under review by the licensee; b) objective, so far as is possible; i.e., the less judgmental the assessment method, and the criteria used to judge performance, the less uncertainty there will be about the validity of the assessment. This is of particular relevance to on-job assessment; c) reliable; i.e., if repeated, the assessment would be likely to produce the same results again. Frequency of assessment 5.42 Assessment should not be regarded as a one-off activity which takes place after initial training, and which "qualifies" a person for the period that he/she subsequently remains in post. A person's competence may change over time as a result of influences such as the frequency with which a task is performed, the varying circumstances under which the task may be performed, or changes to plant or equipment. Loss of memory for the task and the procedures or arrangements which affect the way it is performed may also be compounded by factors such as the development of bad habits, short-cuts etc. Changes to plant operational parameters or procedures may also take place when a person is away for an extended period. All these factors support the case for periodic re-assessment to ensure that personnel are informed about relevant changes, and that they are competent to carry out their jobs. 2017/ Page 15 of 27

16 5.43 The frequency of re-assessment should be influenced by consideration of the following issues: a) the safety significance of the roles and associated tasks which the person performs, as identified through the job and task analysis and formalised in the safety case; b) the (in)frequency with which the tasks are performed; c) the nature of the task (including whether it changes) and the inherent likelihood of loss of competence over time; d) operational experience feedback originating both within the licensee and from other organisations; e) compliance with standards defined nationally or by other accredited or authoritative bodies The Inspector should consider: i) does the licensee have formally-defined provisions for assessing the competencies of all personnel whose activities impact upon safety; ii) has the licensee put in place robust processes for satisfying itself as to the competencies of its contractors where they are not subject to the licensee s competence assessments; iii) is assessment carried out during and/or after training; iv) where possible, is the assessment carried out by a person who is independent of the training which the trainee has received; v) does the choice of assessment method reflect the nature of the competencies which are being assessed, and the training methods and media which are available; vi) can the licensee demonstrate that the assessment methods provide a valid, objective and reliable basis for determining competence; vii) does the licensee act, in a timely manner, upon deficiencies in performance identified through the assessment or during training; viii) has the licensee defined the periodicity of re-assessment which is appropriate for each job or task; ix) does the frequency of re-assessment take into account factors such as the safety significance of the task, the nature of the task and the frequency with which it is performed, plant/procedural changes and operational experience; x) does the licensee have a defined strategy for addressing failures to meet the required standards following training? Evaluation of training effectiveness 5.45 Training is effective only in as much as the learning acquired through training transfers into the real situation. For example, training on a simulator is of limited benefit if it provides trainees with the skills needed to operate the simulator but not the real plant; and classroom training which equips students with the capability to understand thermal 2017/ Page 16 of 27